This newsletter is a listing of the latest changes in export control regulations through September 30, 2026. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and
persons denied export privileges by the United States Government.
REGULATORY UPDATES
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Department of State, Directorate of Defense Trade Controls (DDTC)
Amendment to the International Traffic in Arms Regulations: Prohibited Exports, Imports, and Sales to or From Certain Countries-Cyprus
September 11, 2026: 91 Fed. Reg. 57787: The Department of State amends section 126.1 of the International Traffic in Arms Regulations (ITAR) (22 CFR parts 120 through 130) to specify that the Republic of Cyprus’ status as a proscribed destination is suspended from October 1, 2026, through September 30, 2027.
As a result, certain exemptions to licensing requirements continue to be available for exports, reexports, retransfers, and temporary imports destined for or originating in the Republic of Cyprus and brokering activities involving the Republic of Cyprus, provided the conditions for use of those exemptions are met. Applications for licenses and other authorizations submitted to the Directorate of Defense Trade Controls involving the Republic of Cyprus and nationals of the Republic of Cyprus are subject to case-by-case review.
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DDTC – Data Collection Modernization (DCM) Deployed to the DECCS Production Environment
September 14, 2026: DDTC completed the deployment of DCM to the DECCS environment. This deployment includes updates to the licensing forms, DSP-5, DSP-6, DSP-61, DSP-62, DSP-73, and DSP-74. DDTC posted to its FAQ page a DCM Phase 1 table that describes the changes to each form.
https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_faq_detail&sysparm_article=KB0013236
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=269718291b9bc310fd4d87f4604bcb32
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Review Your DECCS Corporate Administrator Assignments
September 14, 2026: DDTC posted to the DECCS home page a notice urging industry to review its DECCS Corporate Administration Assignments. DDTC has seen an increase in Help Desk support tickets related to Corporate Administrator (CA) access issues, often caused by companies and organizations registered with DDTC having only one CA assigned. To help prevent disruptions, companies, organizations and CAs are urged to review the user management application in DECCS and ensure that multiple users are assigned the CA role. This will help prevent loss of the ability to access DECCS by your company and allow the management of DECCS user accounts and access to Registration and Licensing applications in DECCS.
A CA is a designated individual within the company or organziation responsible for managing DECCS user accounts and roles, providing access to Registration and Licensing applications in DECCS. CAs also have visibility into all submissions and approvals of filings made by your company or organization across all applications, and can access, edit, upload.
Once a new CA is added, ensure the proper roles are granted to allow full access to the necessary functions.
Helpful Articles:
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Waiver of Sanctions on Syria Under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991
September 16, 2026: 91 Fed. Reg. 58740: The Department of State published a Public Notice announcing the Under Secretary For Arms Control and Nonproliferation’s determination to waive the following sanctions on Syria:
- Arms Sales: Termination of (a) sales to Syria under the Arms Export Control Act of any defense articles, defense services, or design and construction services, and (b) licenses for the export to Syria of any item on the United States Munitions List.
- Arms Sales Financing: Termination of all foreign military financing for Syria under the Arms Export Control Act.
This notice is effective on September 16, 2026.
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Modification of USML Category XX(a) in the ITAR
September 17, 2026: 91 Fed. Reg. 59063: DDTC published an interim final rule, effective October 19, 2026. that will remove certain uncrewed underwater vehicles (UUVs) from the International Traffic in Arms Regulation’s (ITAR) U.S. Munitions List (USML).
This rule is in furtherance of the President’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to Improve Speed and Accountability,” which directed the Department to review the US Munitions List (“USML”) to ensure that it focused “on our most sensitive and sophisticated technologies.” The Department of State assessed that these items no longer provide a critical military or intelligence advantage and, therefore, do not warrant continued control under the ITAR and Arms Export Control Act (AECA) and would be more properly controlled by the Department of Commerce’s Export Administration Regulations (EAR).
This rule will take effect on October 19, 2026. The Department is seeking public comments on this rule for 30 days. Interested parties may submit comments by October 19, 2026, using one of the methods described in the interim final rule.
https://www.federalregister.gov/d/2026-19211
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Clarifying ITAR Policies of Denial, Updating Country Policies, and Correcting Minor Textual Errors
September 18, 2026: 91 Fed. Reg. 59059: The Department published a final rule (FR Doc. 2026-19161) in the Federal Register, effective immediately, amending the ITAR to clarify certain ITAR § 126.1 provisions, add Saudi Arabia and Peru to the ITAR’s major non-NATO ally list, and make other minor corrections and clarifications, including:
- Codifying the Secretary of State’s termination of the Ethiopia policy of denial for exports of defense articles and defense services destined to or for the armed forces, police, intelligence, or other internal security forces of Ethiopia that was initially announced on May 11, 2026.
- Revising the text of the Libya, Somalia, and South Sudan country policy paragraphs to ensure clarity and consistency with ITAR nomenclature.
- Correcting an inconsistency in the ITAR § 126.5 Canadian exemptions to confirm that certain transfers do not require a Non-Transfer and Use Certificate (DSP-83).
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International Traffic in Arms Regulations: Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections; Corrections
September 23, 2026: 91 Fed. Reg. 60299: On September 18, 2026, the Department of State revised the International Traffic in Arms Regulations (ITAR) to clarify certain policy-of-denial provisions, update country policies for Ethiopia and Somalia, add Saudi Arabia and Peru to the list of major non-NATO allies, and make other miscellaneous corrections. That document included incorrect amendatory instructions resulting in the inadvertent removal of regulatory text. This document corrects the final regulations.
Due to an error in amendatory instruction 7 (90 FR 59061), § 125.4 paragraphs (b)(10)(i) through (iii) were inadvertently removed by the failure of the amendatory instruction to limit the revision to paragraph (b)(10) introductory text. Similarly, due to an error in amendatory instruction 9.a. (90 FR 59061), § 126.1 paragraphs (a)(2) and (3) were inadvertently removed by the failure of the amendatory instruction to limit the revision to paragraph (a) introductory text and paragraph (a)(1). The Department issued a correction to the regulations and reinserts § 125.4 paragraphs (b)(1)(i) through (iii) and § 126.1 paragraphs (a)(2) and (3) at their prior locations.
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DDTC Name And Address Changes Posted To Website
September 1, 2026 through September 30, 2026: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- CEVA Air & Ocean Spain, S.A.U. changed its name to CEVA Freight Espana S.L.U
- Bollore Logistics UK Ltd changed its name to CEVA Air & Ocean UK
- TRS AMDCS SAS located at 1-5 avenue Camot, Massy, Cadex, France 91883 changed its name and address to Thales LAS France SAS, 2 avenue Gay Lussac, Elancourt, Cedex, France 7899
- Sumisho Aero-Systems Corporation changed its address from 1-2-2, Hititsubashi, Chiyoda-ku Tokyo, 100-0003, Japan to 2-4-6, Akasaka, Minato-ku Tokyo, 107-0052, Japan
- ITOCHU Corporation changed its address from 5-1, Kita-Aoyama 2-chome, Minato-ku Tokyo 107-8077, Japan to Akasaka Trust Tower, 17-22, Akasaka 2-chome, Minato-ku, Tokyo, 107-8077, Japan
- Cornet Technology, Inc. changed its address from 6800 Versar Center, Suite 216 Springfield VA 22150 to 7600 Boston Blvd. Springfield, VA 2215
- L3Harris Linchpin Labs, Inc. changed its name to L3Harris Cyber – CYONYX
- Geneoa Design International Ltd. changed its name to GDIL Operating Limited Partnership.
- L3Harris International subsidiaries changed its as follows:
- L3Harris Trenchant NZ Limited to L3Harris Cyber-CYONYX NZ Limited
- L3Harris Trenchant Ltd to L3Harris Cyber-CYONYX UK Ltd.
- L3Harris Trenchant Pty Ltd to L3Harris Cyber-CYONYX Australia Pty Ltd
- L3Harris Trenchant Canada, Inc. to L3Harris Cyber-CYONYX Canada, Inc.
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Bureau of Political-Military Affairs
BPMA Notified Congress of Potential FMS Sales to the following countries, the details of which can be found at the links below:
- Kingdom of Saudi Arabia – AGT-1500 Engines
- Kingdom of Saudi Arabia – Joint Direct Attack Munitions – Extend Range
- Oman – F-16 Sustainment
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/09/oman-f-16-sustainment/
- United States and Poland Sign $4 Billion Foreign Military Financing Loan Guarantee, Bringing Total U.S. Support to Nearly $20 Billion
- Spain – Sonar Upgrade Kits
- Kingdom of Saudi Arabia – F-35 Lightning II Joint Strike Fighter Aircraft
- Ukraine – Air Defense Development Upgrade
- Denmark – MH-60R Multi Mission Helicopters
- Japan – Ferry Support
https://www.state.gov/releases/bureau-of-political-military-affairs/2026/09/japan-ferry-support/
- Greece – Aircraft Repair and Return Support
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Bureau of Political-Military Affairs Announces Members for the Defense Trade Advisory Group
September 25, 2026: The Assistant Secretary for the Bureau of Political Military Affairs Fleet White announced the appointment of 38 new and returning members to the Defense Trade Advisory Group (DTAG) for 2026-2028:
| James Bartlett | Full Circle Trade Law, PLLC |
| Nathaniel Bolin | K&L Gates LLP |
| Andrew Booth | Sierra Nevada Company, LLC |
| Melissa Burgess | Miller & Chevalier Chartered |
| Rachel Carter | Oshkosh Corporation |
| Steven Casazza | Defense Trade Solutions |
| Samantha Clark | Palantir Technologies |
| Iris Conrad | Amazon Web Services |
| Randall Cook | Alvarez & Marsal |
| Gregory Creeser | ITC Strategies, LLC |
| Matt Cronin | Andreessen Horowitz |
| Patricia Dudley | General Dynamics Corporation |
| Michael Faucette | Wiley Rein LLP |
| Larry Fink | The Boeing Company |
| Krista Helvey | Thales Defense & Security, Inc. |
| Gregory Hill | Leonardo DRS, Inc. |
| Scott Jackson | Anduril Industries |
| Robert Kearsley | Sandia National Laboratories |
| Christopher Martin | L3Harris Technologies, Inc. |
| Jennifer Martin | Leidos, Inc. |
| Timothy McLaughlin | Honeywell Aerospace |
| William Jeff Merrell | Rolls-Royce North America |
| Mitchell, Alexis | Lockheed Martin Corporation |
| FranMarie Mulla | Moog, Inc. |
| Micah Murphy | New American Industrial Alliance |
| Michael Pantschyschak | BAE Systems |
| Kimberly Pritula | National Shooting Sports Foundation |
| Renata Rice | Northrup Grumman Corporation |
| Jeffrey Sammon | TE Connectivity |
| Lori Scheetz | Wiley Rein LLP |
| Craig Schwartz | Nominal |
| Arthur Shulman | General Atomics |
| Libby Smith | Vantour, Inc. |
| Christopher Stewart | AeroVironment, Inc. |
| Jessica Steffens | American Defense International, Inc. |
| Robert Swope | American Global Strategies |
| Brian Walsh | Quartermaster AI |
| Brian Warshawsky | University of California |
These appointed experts will provide vital independent advice and recommendations on issues involving U.S. laws, policies, and regulations regarding exports of defense articles, defense services, and related technical data, including both Foreign Military Sales and Direct Commercial Sales. Members were selected from a nationwide pool of competitive applicants, solicited through a Federal Register Notice in March 2026.
The DTAG operates under the provisions of the Federal Advisory Committee Act (FACA). Upcoming public meetings will be announced in the Federal Register.
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Department of Commerce – Bureau of Industry and Security (BIS)
Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; Five-Year Records Retention Requirement for Export Transactions and Boycott Actions
September 30, 2026: 91 Fed. Reg. 61821: The Department of Commerce’s Bureau of Industry Security (“BIS”) submitted the following information collection request to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995. BIS invites the general public and other Federal agencies to comment on proposed, and continuing information collections, which helps us assess the impact of BIS’s information collection requirements and minimize the public’s reporting burden. Public comments were previously requested via the Federal Register on June 24, 2026, during a 60-day comment period. This notice allows for an additional 30 days for public comments.
Written comments and recommendations for the proposed information collection should be submitted within 30 days of the publication of this notice on the following website www.reginfo.gov/public/do/PRAMain. Find this particular information collection by selecting “Currently under 30-day Review—Open for Public Comments” or by using the search function and entering either the title of the collection or the OMB Control Number 0694-0096.
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Department of the Treasury – Office of Foreign Assets Control (OFAC)
Terrorism List Governments Sanctions Regulations
September 25, 2026: 91 Fed. Reg. 60825: The Office of Foreign Assets Control (OFAC) amended the Terrorism List Governments Sanctions Regulations to implement changes resulting from the rescission of the designation of Syria as a State Sponsor of Terrorism. Specifically, OFAC removed and reserved a Syria-specific general license because the authorization is no longer necessary following the rescission.
This rule is effective September 25, 2026.
LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don’t let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Fines and Penalties
Armenian Man Sentenced To Federal Prison For Smuggling Controlled Goods To Russia
September 2, 2026: An Armenian national was sentenced in a federal court in Austin, Texas on September 2nd to 26 months in prison for his participation in a criminal conspiracy to export goods from the United States to the Russian Federation through the Republic of Armenia without the requisite license or authorization from the U.S. government, announced U.S. Attorney Justin R. Simmons for the Western District of Texas.
According to court documents, from February 2022 until at least August 2024, Kamo Kirakosyan knowingly and willfully combined, conspired, and agreed with others to export and reexport goods subject to the Export Administration Regulations without having first obtained the required export licenses from the U.S. Department of Commerce, Bureau of Industry & Security. The exported goods included items that could be used for semiconductor manufacturing.
Kirakosyan became the straw or substitute purchaser of the U.S.-origin goods for his co-conspirators shortly after Russia’s full-scale invasion of Ukraine on Feb. 24, 2022, and the imposition of additional sanctions and export restrictions on Russia. As part of the scheme, Kirakosyan sent a co-conspirator instructions on opening a bank account in Armenia for the purpose of evading sanctions. While arranging the transshipment of goods to Russia, Kirakosyan represented himself to U.S. companies as the Armenian buyer of goods and did not provide truthful information about the end users, despite the U.S. companies’ requests for end user statements, and despite Kirakosyan’s knowledge that the unauthorized export or reexport to Russia of certain shipments was prohibited without a license. On Feb. 23, 2023, the company Kirakosyan conspired with was designated by Department of the Treasury, Office of Foreign Assets Control and added to the Specially Designated Nationals and Blocked Persons List, subjecting the Russian company to U.S. blocking sanctions and a general prohibition on transacting with U.S. persons or entities.
Kirakosyan was initially charged in a criminal complaint on or about July 31, 2024. He was extradited from Germany to the U.S. on Aug. 29, 2025, and, in April of this year, pleaded guilty to one count of conspiracy to violate federal law.
The FBI San Antonio Counterintelligence Task Force, comprised of the Bureau of Industry and Security of the U.S. Department of Commerce, and other partners, led the investigation. The FBI’s Legal Attaché office in Berlin provided significant assistance. The Justice Department’s Office of International Affairs also played a key role in securing Kirakosyan’s extradition to the United States.
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An Individual Settles With OFAC For $1,427,230 Related To Apparent Violations Of Iran-Related Sanctions Regulations
September 10, 2026: A natural U.S. person (“U.S. Person-1”) has agreed to pay $1,427,230 to settle their potential civil liability for 39 apparent violations of OFAC sanctions on Iran. Between June 26, 2019 and July 7, 2021, U.S. Person-1 provided management consulting and advisory services to one of Iran’s leading software solutions companies, received Iranian-origin dividends to their U.S. bank accounts, and acquired real property in Iran. The settlement amount reflects OFAC’s determination that the apparent violations were not voluntarily self-disclosed and were egregious.
In 1987, while living in Iran, U.S. Person-1 co-founded Iranian Company-1, an Iranian software solutions company. After Iranian Company-1 became a publicly listed company in Iran in 2011, U.S. Person-1 co-founded Iranian Company-2, an Iran-incorporated holding company, to maintain U.S. Person-1’s ownership interest in Iranian Company-1.
As of 2026, Iranian Company-1 has grown to become one of Iran’s leading software solutions companies, providing financial, administrative, human resources, logistics, and management software for critical industries in the Iranian economy, including the petrochemical, pharmaceutical, construction, and agricultural sectors, as well as government agencies, universities, research centers, and state-owned enterprises.
Over many years, U.S. Person-1 maintained their connections to the companies. Between July 10, 2019 and October 23, 2020, U.S. Person-1 provided management consulting and advisory services to Iranian Company-1 or Iranian Company-2 by actively participating in 19 virtual meetings with senior Iranian Company-1 or Iranian Company-2 personnel to discuss company matters. Participants in these meetings, including U.S. Person-1, discussed corporate transactions, asset management, sales, marketing, accounting, human resources, corporate governance, and overall company strategy. For some of the meetings, U.S. Person-1 drafted the agenda. The other participants in the meetings included Iranian Company-1 directors and officers, including the Chief Executive Officer of Iranian Company-1 who co-founded Iranian Company-1 with U.S. Person-1, the Chairman of Iranian Company-1’s Board of Directors, and an Iranian Company-1 employee who served as Secretary of the Board of Directors. During these meetings, U.S. Person-1 provided substantive advice, analysis, and information.
Separately, between June 26, 2019 and August 28, 2020, on 16 occasions, U.S. Person-1 arranged for their Iranian-origin dividend payments from Iranian Company-1 or Iranian Company-2 to be deposited into U.S. financial institutions via wire transfers. These wire transfers, which transited through banks in third countries such as Türkiye, the United Arab Emirates, and Singapore, were ultimately paid into U.S.-based bank accounts held in U.S. Person-1’s name. In total, U.S. Person-1 received $713,615 in dividend payments.
Additionally, in or after 2021, U.S. Person-1 purchased four real estate properties in Iran for the benefit of relatives residing there with the proceeds of other dividend payments. U.S. Person-1 later abandoned their ownership interest in Iranian Company-1 or Iranian Company-2 in 2022.
Throughout the relevant time period, U.S. Person-1 was aware of U.S. sanctions on Iran. In 2000, while serving as an executive at Iranian Company-1 in Iran, U.S. Person-1 co-authored an article in a leading newspaper about Iran’s digital revolution and the challenges of the Iran sanctions program to Iran’s information technology sector.
U.S. Person-1 received an administrative subpoena from OFAC in January 2025. U.S. Person 1’s response was initially incomplete. In July 2025, OFAC issued a second administrative subpoena to U.S. Person-1, citing deficient responses to the first administrative subpoena. U.S. Person-1 subsequently provided a complete response.
In engaging in the conduct described above, U.S. Person-1: (1) provided management consulting and advisory services to Iran on 19 occasions; (2) caused U.S. financial institutions to indirectly export financial services to Iran by processing Iranian-origin dividends on 16 occasions; and (3) purchased real property in Iran with the Iranian-origin dividends on four occasions, in apparent violation of sections 560.203, 560.204, and 560.207 of the Iranian Transactions and Sanctions Regulations (ITSR) (the “Apparent Violations”), respectively.
https://ofac.treasury.gov/media/936911/download?inline
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Russian National Pleads Guilty To Smuggling U.S. Aerospace Goods To Russia
September 14, 2026: Andrei Samuilovski,32, who has citizenship in Estonia, Switzerland, and Russia, pleaded guilty on September 14, 2026 in connection with a scheme to illegally export U.S.-origin aviation and aerospace parts to Russia in violation of U.S. sanctions.
Samuilovski pleaded guilty before Judge Carl J. Nichols to a one count information charging him with conspiracy to violate the Export Control Reform Act of 2018 (ERCA). A sentencing date is scheduled for Jan. 13, 2027. Samuilovski faces a maximum penalty of 20 years in prison.
According to court documents, beginning in or around early 2022 and continuing through September 2024, Samuilovski and others conspired to supply prohibited Russian end users with aerospace-related components without first obtaining the required Export Administration Regulations (EAR) export licenses from the Department of Commerce’s Bureau of Industry and Security (BIS). BIS regulates the export of U.S.-origin technologies, including aerospace parts and other items controlled for national security, regional stability, and anti-terrorism reasons. An export license from BIS was required to export the aerospace commodities to Russia.
Samuilovski was a co-founder of ITC Middle East FZ-LLC (ITC). ITC was officially established in March of 2022, approximately four weeks after Russia’s invasion of Ukraine, which led to increased Russian export restrictions and sanctions imposed by the United States, European Union, and other countries.
Between the founding of ITC and September 2024, there were dozens of shipments from various U.S. companies to ITC, as well as other shipments of U.S.-origin goods to ITC. The U.S.-origin items exported or reexported consisted primarily of export-controlled aerospace-related commodities with a cumulative value of nearly $2,000,000. These items were ultimately reexported to Russia.
The investigation was conducted by the FBI and the BIS.
https://www.justice.gov/opa/pr/russian-national-pleads-guilty-smuggling-us-aerospace-goods-russia
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Two Canadian Men Plead Guilty To Attempting To Illegally Export Firearms From The U.S. To Dubai And Columbia
September 14, 2026: U.S. Attorney Michael DiGiacomo announced that Guy Deland a/k/a Mark a/k/a Security Prime, 68, and Charan Singh, 56, both from Quebec, Canada, pleaded guilty before U.S. District judge Richard J. Arcara to conspiracy to violate the Arms Export Control Act (AECA), which carries a maximum penalty of five years in prison and a fine of $250,000 for this transactions.
Between November 2016 and April 2017, Deland and Singh conspired with others, including Aydan Sin, to export defense articles ,without an export license, described on the ITAR’s United States Munitions List (USML) in violation of United States law.
In November 2016, Singh began communicating with an undercover law enforcement agent (UCA), inquiring about whether the UCA could export firearms from the United States to the United Arab Emirates. During the communications, Singh, Deland, and Sin were advised by the UCA that an export license was required from the United States Department of State in order to legally export the firearms. The defendants acknowledged the illegality of the attempted exports, provided an encrypted Blackberry device to the UCA for the purpose of secure, covert communications, and wired approximately $70,000 USD from Canada to the United States as a 50% down payment for the export of the goods.
On December 7, 2016, Sin, through telephone and email, requested the gun order include 9mm handguns and Uzi machine guns. On December 9, 2016, Sin told the UCA that rather than get an export license, he wanted the UCA to export the firearms “the wrong way.”
Subsequently, on January 10, 2017, the UCA emailed two revised invoices to Deland and Sin. One invoice was for the export to Dubai of three new Glock 9mm firearms, six magazines, two used Mini Uzi submachine guns, two suppressors, and 1,000 rounds of 9mm ammunition for the firearms, for a total cost of $20,575. The second invoice was for the export to Colombia (thru Panama) of 37 new Glock 9mm firearms, 74 magazines, 13 used Mini Uzi submachine guns, 13 suppressors, and 3,000 rounds of 9mm ammunition for the firearms, for a total cost of $121,175. Both invoices contained language stating that exporting these products was prohibited by law without an export license. On February 6 and 7, 2017, an undercover bank account, located in the Western District of New York, received two bank wire transfers from a bank account in Canada, each in the amount of $34,990 USD, representing 50% of the total purchase price of the firearms, suppressors, and ammunition.
On March 10, 2017, Sin contacted the UCA and asked if the shipment of guns to Columbia would occur in a few days. On March 20, 2017, the UCA used existing sea freight shipment tracking numbers and told Sin and Deland that the firearms, suppressors, and ammunition were shipped to Jebel Ali, United Arab Emirates, and the shipment of guns to Columbia would occur on March 29, 2017. The UCA also provided them with tracking information.
The case was prosecuted by Assistant U.S. Attorney Aaron J. Mango and Trial Attorney Beaudre Barnes from the Counterintelligence & Export Control Section of the National Security Division at the Department of Justice. The pleas are the result of an investigation by Homeland Security , under the direction of Acting Special Agent-in-Charge Anthony Patrone. Additional assistance was provided by the Royal Canadian Mounted Police.
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Former U.S. Army Soldier Pleads Guilty To Gathering And Transmitting National Defense Information
September 16, 2026: A Hillsboro, Oregon, man pleaded guilty to conspiracy to gather and transmit national defense information.
Ruoyu Duan, Age 41, pleaded guilty to a superseding information charging conspiracy to gather and transmit national defense information, announced U.S. Attorney Scott E. Bradford for the District of Oregon.
According to court documents, between November 2021 and March 2025, within the District of Oregon and elsewhere, Duan conspired with others to surreptitiously gather sensitive military information related to the United States Army’s operational capabilities, including computer equipment, training materials, intelligence reports, and technical manuals. Duan paid his co-conspirators, active-duty U.S. Army soldiers, and others, to gather information and equipment. Specifically, they obtained information related to U.S. military weapon systems, such as U.S. Army combat vehicles, including the Bradley, Stryker, and HIMARS platforms, and transferred that information to people in China.
Duan served as an U.S. Army soldier from 2013 – 2017 and was trained in the handling of sensitive and classified military information.
On March 5, 2025, a federal grand jury in Portland returned an indictment charging Duan and Li Tian, an Active-Duty U.S. Army Officer, with conspiring to commit bribery and theft of government property.
The FBI arrested Duan in Oregon on March 6, 2025.
Defendant Duan faces a maximum sentence of 10 years in prison, a $250,000 fine and 3 years of supervised release. He will be sentenced on December 10, 2026, before U.S. District Court Judge Karin Immergut.
The case was investigated by the FBI Portland and Seattle Field Offices and U.S. Army Counterintelligence Command, with assistance from the Customs and Border Protection (CBP) Seattle Field Office, CBP Office of Professional Responsibility, United States Postal Inspection Service, and Naval Criminal Investigative Service. The case is being prosecuted by Geoffrey A. Barrow and Katherine A. Rykken, Assistant U.S. Attorneys for the District of Oregon, and Christopher Magnani and Yifei Zheng, Trial Attorneys for the National Security Division’s Counterintelligence and Export Control Section.
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Avionics Company Owner Sentenced To Prison For Thwarting U.S. Customs Laws
September 17, 2026: A Kansas businessman was sentenced to 18 months in prison for violating United States customs laws by selling advanced aviation technology to Russian end users.
According to court documents, Cyril Gregory Buyanovsky, 63, of Lawrence, pleaded guilty to conspiracy and money laundering.
Buyanovsky is the former president and owner of KanRus Trading Company, a Kansas-based avionics enterprise. As part of his plea agreement, Buyanovsky consented to the forfeiture of over $450,000 worth of avionics equipment and accessories and a $50,000 personal forfeiture judgment.
After Russia’s 2022 invasion of Ukraine, the U.S. government tightened export controls concerning Russia. Buyanovsky and KanRus vice president Douglas Edward Robertson, 59, of Olathe conspired to continue to purchase, sell, and export sophisticated and controlled avionics equipment to customers in Russia without the required export licenses from the U.S. Department of Commerce.
Robertson pleaded guilty to export control and money laundering violations and was sentenced to 32 months in prison.
“Congress put trade restrictions in place to discourage Russia’s continued aggression in Ukraine. The defendants ignored those laws and saw the war not as a humanitarian crisis, but as a business opportunity to boost their profits,” said U.S. Attorney Ryan A. Kriegshauser.
“The sentencing of Mr. Buyanovsky marks the final chapter of an investigation that exposed a deliberate conspiracy to circumvent U.S. export-control laws and facilitate the unlawful transfer of advanced aviation technology to Russia following its invasion of Ukraine. This case underscores the FBI’s steadfast commitment to protecting the integrity of our nation’s export-control system and holding accountable those who seek to undermine it. Our message is clear: The FBI will continue to work closely with our law enforcement and government partners to identify, investigate, and disrupt any efforts to exploit our laws,” said Chris Ormerod, FBI Kansas City Special Agent in Charge.
A third defendant, Oleg Chistyakov, a/k/a Olegs Čitsjakovs, 57, of the Republic of Latvia, acted as a broker for KanRus. He was sentenced to 28 months in prison after pleading guilty to his part in the conspiracy.
The Federal Bureau of Investigation (FBI) and the Department of Commerce’s Office of Export Enforcement (OEE) investigated the case. The Latvian authorities assisted in the investigation while U.S. Customs and Border Protection provided substantial assistance.
Assistant U.S. Attorneys Scott Rask and Ryan Huschka for the District of Kansas as well as Adam Barry, a former trial attorney of the National Security Division’s Counterintelligence and Export Control Section, prosecuted the case. The Justice Department’s Office of International Affairs provided valuable assistance.
https://www.justice.gov/usao-ks/pr/avionics-company-owner-sentenced-prison-thwarting-us-customs-laws
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Dual Citizen Convicted Of Smuggling Goods From The United States To Russia
September 23, 2026: The President of a freight forwarding company has been convicted by a federal jury in Boston of unlawfully exporting an Orbitrap Exploris GC 240 Mass Spectrometer from the United States into Russia without a license.
Kirill Gordei, 37, was convicted on September 22, 2026 following a four day trial, of one count of conspiracy to commit offenses against the United States; one count of smuggling goods from the United States; and one count of export of a spectrometer which is a commerce control item. U.S. District Court Judge Myong J. Joun scheduled sentencing for Jan. 12, 2027. Gordei was arrested and charged in June 2024.
Gordei, a citizen of Belarus and the United States who resides in Hallandale, Fla., is the President of Apelsin Logistics, a freight forwarding company, located in Hallandale Beach, Fla. Apelsin also has an address in Russia and two websites both of which are registered and hosted in Russia.
Since Russia’s invasion of Ukraine on Feb. 24, 2022, a series of stringent export controls were implemented that restrict Russia’s access to the technologies and other items that it needs to sustain its attack on Ukraine. As of April 8, 2022, license requirements for exports, reexports and transfers to or within Russia were expanded to cover the most sensitive items subject to controls on the Commerce Control List.
In August 2023, Gordei facilitated the export of an Orbitrap Exploris GC 240 Mass Spectrometer – an item that delivers high data quality and versatility to accelerate scientific discovery for academic, industry research, government and omics laboratories – from the United States to Russia via Turkey, in violation of the licensing requirements. In order to facilitate the transaction, Gordei provided falsified documentation to an American freight forwarding company indicating that the mass spectrometer was destined to Uzbekistan, rather than to Russia. Gordei simultaneously arranged for the mass spectrometer to be shipped directly to Moscow after it arrived in Turkey.
“The Bureau of Industry and Security will relentlessly pursue those who violate U.S. export control laws,” stated David Peters, Assistant Secretary for Export Enforcement, U.S. Department of Commerce. “This conviction demonstrates our commitment to dismantling these dangerous criminal networks.”
The charge of violating the Export Control Reform Act (ECRA) provides for a sentence of up to 20 years in prison, five years of supervised release and a fine of up to $1,000,000. The charge of smuggling goods from the United States provides for a sentence of up to 10 years in prison, three years of supervised release and a fine of up to $250,000. The charge of conspiracy to commit offenses against the United States provides for a sentence of five years in prison, three years of supervised release and a fine of up to $250,000. Sentences are imposed by a federal district court judge based upon the U.S. Sentencing Guidelines and statutes which govern the determination of a sentence in a criminal case.
https://www.justice.gov/usao-ma/pr/dual-citizen-convicted-smuggling-goods-united-states-russia
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Iranian National Sentenced For Scheme To Ship Sensitive Technology To Iran Via China
September 25, 2026: A 44-year-old citizen of Iran was sentenced in U.S. District Court in Seattle to 18 months in prison for his scheme to violate trade sanctions against Iran, announced First Assistant U.S. Attorney Charles Neil Floyd. Reza Dindar, aka Renda Dindar, was indicted by the grand jury in August 2014. Dindar was arrested in Panama in July 2025 at the request of the United States. Dindar was extradited to the U.S. in April 2026. A mere six weeks later he pleaded guilty to two counts of export to an embargoed country and two counts of smuggling goods from the United States. At the sentencing hearing U.S. District Judge Ricardo S. Martinez said, “The offense was well over 10 years ago and Mr. Dindar spent significant time in a Panamanian prison.” The judge imposed a $10,000 fine and three years of supervised release to follow the prison term.
According to records filed in the case, the smuggling in this case violates sanctions against Iran imposed by the President’s Executive Order in March 1995 and reimposed in 2001. The orders prohibit the unauthorized exportation, re-exportation, sale, or supply, directly or indirectly, from the United States of any goods, technology, or services to Iran or the Government of Iran; as well as the exportation or supply of goods, technology, or services to persons in third countries knowing or with reason to know that the goods, technology or services are intended for supply, trans-shipment, or re-exportation to Iran.
According to the plea agreement, between 2010 and 2014, Dindar managed a business called New Port Sourcing Solutions in Xi’an, China. The company hid the fact that it was procuring items in the U.S. for companies in Iran. It fraudulently claimed the goods were destined for China. In 2011 and 2012, Dindar and his coconspirators used deception to purchase parts for three military sonar systems from a business in the Western District of Washington. Dindar and his coconspirators claimed the systems would be used by a company in China. In fact, the plan was to ship the parts through China to Iran in violation of export controls.
In asking for an 18-month prison sentence prosecutors wrote to the court, “The export controls put into effect through the International Emergency Economic Powers Act (IEEPA) are essential to the United States’ national security interests. Therefore, it is important for the Court’s sentence to provide adequate deterrence against similar offenses moving forward. A custodial sentence of 18 months would achieve the statutory goal of deterrence by exceeding the national average and median sentences for similar offenses committed by defendants with similar backgrounds.”
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Sanctions
Department of Commerce – Bureau of Industry and Security (BIS)
Order Renewing Temporary Denial of Export Privileges Against UTair Aviation JSC of Russia
September 17, 2026: 91 Fed. Reg. 58846: BIS renewed the temporary denial of export privileges against UTair Aviation JSC (“UTair”) because it has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the Export Administration Regulations (“EAR”).
The Temporary Denial Order (“TDO”) prohibits:
- UTair, when acting for or on their behalf, any successors or assigns, agents, or employees from directly or indirectly, participating in any way in any transaction involving any commodity, software or technology (hereinafter collectively referred to as “item”) exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to the EAR.
- Other persons and entities from directly or indirectly, do any of the following:
- Exporting, reexporting, or transferring (in-country) to or on behalf of UTair any item subject to the EAR except directly related to safety of flight and authorized by BIS;
- Taking any action that facilitates the acquisition or attempted acquisition by UTair of the ownership, possession, or control of any item subject to the EAR that has been or will be exported from the United States, including financing or other support activities related to a transaction whereby UTair acquires or attempts to acquire such ownership, possession or control except directly related to safety of flight and authorized by BIS;
- Taking any action to acquire from or to facilitate the acquisition or attempted acquisition from UTair of any item subject to the EAR that has been exported from the United States except directly related to safety of flight and authorized by BIS;
- Obtaining from UTair in the United States any item subject to the EAR with knowledge or reason to know that the item will be, or is intended to be, exported from the United States except directly related to safety of flight and authorized by BIS; or
- Engaging in any transaction to service any item subject to the EAR that has been or will be exported from the United States and which is owned, possessed or controlled by UTair, or service any item, of whatever origin, that is owned, possessed or controlled by UTair if such service involves the use of any item subject to the EAR that has been or will be exported from the United States except directly related to safety of flight and authorized by BIS.
https://www.bis.gov/media/documents/utair-aviation-jsc.pdf
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Order Renewing Temporary Denial of Export Privileges Against Azur Air of Russia
September 17, 2026: 91 Fed. Reg. 58843: BIS renewed the temporary denial of export privileges against Azur Air (“Azur”) because it has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR.
The Temporary Denial Order (“TDO”) prohibits:
- Azur, when acting for or on their behalf, any successors or assigns, agents, or employees from directly or indirectly, participating in any way in any transaction involving any commodity, software or technology (hereinafter collectively referred to as “item”) exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to the EAR.
- Other persons and entities from directly or indirectly, do any of the following:
- Exporting, reexporting, or transferring (in-country) to or on behalf of Azur any item subject to the EAR except directly related to safety of flight and authorized by BIS;
- Taking any action that facilitates the acquisition or attempted acquisition by Azur of the ownership, possession, or control of any item subject to the EAR that has been or will be exported from the United States, including financing or other support activities related to a transaction whereby Azur acquires or attempts to acquire such ownership, possession or control except directly related to safety of flight and authorized by BIS;
- Taking any action to acquire from or to facilitate the acquisition or attempted acquisition from Azur of any item subject to the EAR that has been exported from the United States except directly related to safety of flight and authorized by BIS;
- Obtaining from Azur in the United States any item subject to the EAR with knowledge or reason to know that the item will be, or is intended to be, exported from the United States except directly related to safety of flight and authorized by BIS; or
- Engaging in any transaction to service any item subject to the EAR that has been or will be exported from the United States and which is owned, possessed or controlled by Azur, or service any item, of whatever origin, that is owned, possessed or controlled by Azur if such service involves the use of any item subject to the EAR that has been or will be exported from the United States except directly related to safety of flight and authorized by BIS
https://www.bis.gov/media/documents/azur-air-tdo-renewal.pdf
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Order Renewing Temporary Denial of Export Privileges Against PJSC Aeroflot of Russia
September 17, 2026: 91 Fed. Reg. 58840: BIS renewed the temporary denial of export privileges against PJSC Aeroflot (“Aeroflot”) because it has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR.
The Temporary Denial Order (“TDO”) prohibits:
- Aeroflot, when acting for or on their behalf, any successors or assigns, agents, or employees from directly or indirectly, participating in any way in any transaction involving any commodity, software or technology (hereinafter collectively referred to as “item”) exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to the EAR.
- Other persons and entities from, directly or indirectly, do any of the following:
- Exporting, reexporting, or transferring (in-country) to or on behalf of Aeroflot any item subject to the EAR except directly related to safety of flight and authorized by BIS;
- Taking any action that facilitates the acquisition or attempted acquisition by Aeroflot of the ownership, possession, or control of any item subject to the EAR that has been or will be exported from the United States, including financing or other support activities related to a transaction whereby Aeroflot acquires or attempts to acquire such ownership, possession or control except directly related to safety of flight and authorized by BIS;
- Taking any action to acquire from or to facilitate the acquisition or attempted acquisition from Aeroflot of any item subject to the EAR that has been exported from the United States except directly related to safety of flight and authorized by BIS;
- Obtaining from Aeroflot in the United States any item subject to the EAR with knowledge or reason to know that the item will be, or is intended to be, exported from the United States except directly related to safety of flight and authorized by BIS; or
- Engaging in any transaction to service any item subject to the EAR that has been or will be exported from the United States and which is owned, possessed or controlled by Aeroflot, or service any item, of whatever origin, that is owned, possessed or controlled by Aerflot if such service involves the use of any item subject to the EAR that has been or will be exported from the United States except directly related to safety of flight and authorized by BIS.
https://www.bis.gov/media/documents/pjsc-tdo-renewal.pdf
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Order Renewing Temporary Denial of Export Privileges Against Ural Airlines JSC of Russia
September 29, 2026: 91 Fed. Reg. 61384: BIS renewed the temporary denial of export privileges against Ural Airlines JSC (“Ural”) because it has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR.
The Temporary Denial Order (“TDO”) prohibits:
- Ural, when acting for or on their behalf, any successors or assigns, agents, or employees from directly or indirectly, participating in any way in any transaction involving any commodity, software or technology (hereinafter collectively referred to as “item”) exported or to be exported from the United States that is subject to the EAR, or in any other activity subject to the EAR.
- Other persons and entities from, directly or indirectly, do any of the following:
- Exporting, reexporting, or transferring (in-country) to or on behalf of Ural any item subject to the EAR except directly related to safety of flight and authorized by BIS;
- Taking any action that facilitates the acquisition or attempted acquisition by Ural of the ownership, possession, or control of any item subject to the EAR that has been or will be exported from the United States, including financing or other support activities related to a transaction whereby Ural acquires or attempts to acquire such ownership, possession or control except directly related to safety of flight and authorized by BIS;
- Taking any action to acquire from or to facilitate the acquisition or attempted acquisition from Ural of any item subject to the EAR that has been exported from the United States except directly related to safety of flight and authorized by BIS;
- Obtaining from Ural in the United States any item subject to the EAR with knowledge or reason to know that the item will be, or is intended to be, exported from the United States except directly related to safety of flight and authorized by BIS; or
- Engaging in any transaction to service any item subject to the EAR that has been or will be exported from the United States and which is owned, possessed or controlled by Ural, or service any item, of whatever origin, that is owned, possessed or controlled Ural if such service involves the use of any item subject to the EAR that has been or will be exported from the United States except directly related to safety of flight and authorized by BIS.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
The following is a summary of OFAC actions for September 1 through September 30, 2026.
- Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260902
- Further Sanctions on Cuba’s Elites, Financial Channels, and Resource Exploitation Apparatus
- Cuba Designations; Russia-related Designation Removal; Issuance of Amended Cuba General License
https://ofac.treasury.gov/recent-actions/20260903
- Treasury Severs Iranian Regime’s Financial Lifelines in Türkiye
https://home.treasury.gov/news/press-releases/sb0622/
- Iran-related Designations; Issuance of Iran-related General License
https://ofac.treasury.gov/recent-actions/20260904
- Treasury Grounds Iranian Airlines with Sweeping Sanctions Action
https://home.treasury.gov/news/press-releases/sb0623/
- Iran-related Designations; Counter Terrorism Designations; Updates to Iran-related General Licenses; Issuance of Counter Terrorism General License
https://ofac.treasury.gov/recent-actions/20260908
- Treasury Cracks Down on Transnational Criminal Organization Behind Cyber Scam Operations Targeting Americans
https://home.treasury.gov/news/press-releases/sb0624/
- Transnational Criminal Organizations Designations; Counter Terrorism Designation; Issuance of New and Amended Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260909
- Operation Economic Outcast Strikes Iran’s Global Terrorist Proxy Network
https://home.treasury.gov/news/press-releases/sb0626/
- Iran-related and Counter Terrorism Designations; Licensing Policy Update under Operation Economic Outcast; Settlement Agreement between OFAC and an Individual
https://ofac.treasury.gov/recent-actions/20260910
- Operation Economic Outcast Sanctions Major Bank Helping Iran Evade Sanctions
https://home.treasury.gov/news/press-releases/sb0629/
- Iran-related Designation; Issuance of Amended Venezuela-related General License and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260914
- Russia-related Designations Removals; Counter Narcotics Designation Removal; Issuance of Amended Venezuela General License and Frequently Asked Question
https://ofac.treasury.gov/recent-actions/20260916
- Operation Economic Outcast Disrupts Digital Asset Exchange Enabling the Iranian Regime
https://home.treasury.gov/news/press-releases/sb0632/ - Further Sanctions on Cuba’s Mineral Wealth and Military Modernization Apparatus
- Iran-related Designations; Cuba Designations; Belarus-related Designations Removals
https://ofac.treasury.gov/recent-actions/20260917
- Expiration of Emergency With Respect to the Situation in Ethiopia; Ethiopia-related Designations Removals; Issuance of Amended Russia-related General License and Associated Frequently Asked Questions
https://ofac.treasury.gov/recent-actions/20260918
- Democratic Republic of the Congo-related Designations Removals
https://ofac.treasury.gov/recent-actions/20260923
- Publication of Regulatory Amendments; Publication of Report for Licensing Activities Undertaken Pursuant to the Trade Sanctions Reform and Export Enhancement Act (TSRA)
https://ofac.treasury.gov/recent-actions/20260924
- Issuance of Amended Venezuela General Licenses
https://ofac.treasury.gov/recent-actions/20260928
- Publication of Regulatory Amendments; Publication of Cuba Sanctions Regulations; Issuance of New and Amended Cuba-related Frequently Asked Questions; Publication of Cuba-related OFAC Alert
https://ofac.treasury.gov/recent-actions/20260929_33
- Operation Economic Outcast Takes Down Iranian Military Procurement Networks
https://home.treasury.gov/news/press-releases/sb0637/
- Treasury Sanctions Sinaloa Cartel Leadership and Corruption Networks
https://home.treasury.gov/news/press-releases/sb0636/
- Counter Narcotics, Counter Terrorism, Iran-related, and Non-Proliferation Designations
https://ofac.treasury.gov/recent-actions/20260929
- Treasury Sanctions Financial Network of Foreign Terrorist Organization, Tren de Aragua, After Theft of Millions from U.S. Banks
https://home.treasury.gov/news/press-releases/sb0640/
- Counter Terrorism and Transnational Criminal Organizations Designations; Belarus, Counter Narcotics, and Libya Designations Removals
https://ofac.treasury.gov/recent-actions/20260930